No CapX 2020

From the public meeting materials, here’s what they’re looking at, above.  These are significant additions to the transmission grid in Minnesota and Wisconsin.  Look at the number of double circuits they want to add, and look at the new transmission planned for Minnesota and WIsconsin.  And note how, as with CapX 2020, it’s starting in the coal fields of the Dakotas.

MISO’s Economic Planning Users Group is planning a “Regional Transmission Overlay Study” and they’re having another meeting tomorrow, May 25, 2017 down in Metatairie, Louisiana.

Here’s the call in info:

WebEx Information
Event Number: 966 575 350
WebEx Password: Ts824634

Participant Dial-In Number: 1-800-689-9374
Participant Code: 823713

Meeting Materials from the MISO site:

• 20170525 EPUG Item 01 Agenda 5/23/2017 05:24 PM
• 20170525 EPUG Item 02 Regional Transmission Overlay Study Overview 5/22/2017 05:47 PM
• 20170525 EPUG Item 03 Preliminary Overlay Indicative Concepts 5/23/2017 05:29 PM
• 20170527 EPUG Item 04 Explore New Benefit Metrics RECB Survey 5/22/2017 04:42 PM
• 20170525 EPUG Item 05 Michigan Exploratory Transmission Study Transmission_Ideas 5/22/2017 04:44 PM
• 20170525 EPUG Item 05 Michigan Exploratory Transmission Study Update 5/22/2017 04:44 PM
• 20170525 EPUG Item 06a Indicative Overlay Design Work Session West 5/24/2017 02:20 PM
• 20170525 EPUG Item 06b Indicative Overlay Design Work Session Central 5/24/2017 02:21 PM
• 20170525 EPUG Item 06c Indicative Overlay Design Session Sub-regional Connections 5/24/2017 02:22 PM
• 20170525 EPUG Item 06d Indicative Overlay Design Work Session South public 5/24/2017 02:23 PM
• 20170525 EPUG RTOS Issues List 5/23/2017 05:45 PM
• 20170525 EPUG RTOS Ideas Tracking Sheet 5/23/2017 05:44 PM

Here’s the problem — they close the meeting, and people like me aren’t allowed to attend.  First I was told, back in January when I tried to register:

Thank you for registering for the Economic Planning Users Group (EPUG) on Jan 31.  The afternoon portion of this meeting will be held in CLOSED session and reserved from MISO Members or Market Participants only.  Please feel free to attend the morning session from 11:00 am to 12:45 pm ET / 10:00 am to 11:45 CT.

I filled out their “CEII – Non-Disclosure Agreement” form and fired it off.  But noooooo…

So next I went to the PUC’s Quarterly MISO update, where I was assured that we could make arrangements so that I could attend.  I resent the “CEII – Non-Disclosure Agreement” and went back and forth and it came to this (click for larger version).  Note this “explanation” of options to be able to attend:

The reason that you were not permitted to attend the closed session is because the meeting involved discussion of Critical Energy Infrastructure Information (CEII) and CEII access requests by Non-Member Individuals requires FERC clearance.  Another access option is to be included on Appendix A of a MISO member or Market Participant.

So that says there are two ways to gain access, 1) get “FERC clearance” or 2) “Another access option is to be included on Appendix A of a MISO member or Market Participant.”  One or the other. Emphasis added.  Here’s the email (click for larger version) laying out those two options:

Oh, I says to myself, off to FERC.  I sent in the requisite paperwork to FERC, and got “FERC clearance” and they shipped me the CEII information, including but not limited to the map.  I let MISO know I’d obtained “FERC clearance,” and here’s the response (click for larger version):

ARRRRGH, they have my CEII NDA on file, have had it since January 23, 2017.  I resent it to the writer of these emails on March 4, 2017, and I sent it again today, and objected to yet another change in their “rules” (click for larger version):

So the plot thickens — from MISO (click or larger version):

And from moi (click for larger version):

It’s early, so now’s the time to get agitated, get activated!

As if CapX 2020 wasn’t enough, and during the CapX 2020 Certificate of Need proceeding, word of the “JCSP” overlay came out.  And we know that Xcel, in its e21 Initiative, is whining about the grid only being 55% utilized (DOH! Because CapX and other transmission expansion wasn’t needed, was built, and now they’re trying to make us pay for it!).

And as if Obama’s RRTT wasn’t enough, now there’s this, check out Executive Order 13766:

Expediting Environmental Reviews and Approvals for High Priority Infrastructure Projects

And so now the rest of the story — here’s what they’re planning:

Here’s the list, in a spreadsheet:

20170131 EPUG Preliminary Overlay Ideas List

The Minnesota Public Utilities Commission has scheduled the MISO Utilities Quarterly Update Meeting for the Second Quarter of 2017 for Friday, March 3, 2017 from 10:00 AM to Noon in the Commission’s Large Hearing Room, 121 7th Place East, Suite 350, St. Paul, MN 55101.

MISO Q letter 03-10-2014.bh.-1

Note this part, to be discussed at this meeting:

Laying the ground work now for this, a huge build-out that isn’t needed, an overlay on top of transmission that wasn’t needed either.  NO!

The CapX 2020 project has been a part of my life for over 12 years… and now it’s mostly up and running.  So I’ve spent the day digging through the dusty files.  What a mess.  Boxes and boxes and boxes.

That’s a map from 2007 or so with coal plants ID’d from the MISO queue, some up and running, many not (good!).  The north/south line along the MN and ND/SD border is missing.  The North Dakota, South Dakota and Wisconsin legs are all permitted too, much constructed.  Well played, Xcel.

During the Certificate of Need proceeding, we were not able to address the bulk power transfer aspect of this, because after all, “it terminates in Wisconsin.”

Meanwhile, Xcel Energy’s rate case based on its e21 Initiative whines that the grid is only 55% utilized!

You’re not going to be efficient if you’re reliant on massive transmission lines, DOH!  Oh well, we knew all this, and yet here we are, billions of dollars of “wires in the air” and the bills just now arriving.  Xcel argued that No CapX 2020 should be excluded:

But CapX 2020’s Minnesota Brookings – Hampton transmission line is part of MISO’s MVP 17 project portfolio!  DOH!  And the judge apparently missed that Xcel brought up both CapX 2020 cost recovery and MISO MVP cost recovery in their direct testimony!

Oh, but it doesn’t end there…

No CapX 2020 was not allowed to intervene in the rate case and address transmission recovery, after all, the permits have been granted, so WHY DOES NO CAPX EVEN EXIST?!?!?  So said the judge:

Oh well…

Remember their shindig on Tuesday:

September 26, 2016

Time?  They’re not telling…

Hampton Substation

Highway 52 and 215th Street (N. of Hwy. 50)

It’s out, the report from U of M Humphrey School of Public Affairs about CapX 2020, headlining it as a “Model for addressing climate change.“

Transmission Planning and CapX 2020: Building Trust to Build Regional Transmission Systems

Oh, please, this is all about coal, and you know it.  This is all about enabling marketing of electricity.  In fact, Xcel’s Tim Carlsbad testified most honestly that CapX 2020 was not for wind!  That’s because electrical energy isn’t ID’d by generation source, as Jimbo Alders also testified, and under FERC, discrimination in generation sources is not allowed, transmission must serve whatever is there.  And the report early on, p. 4, notes:

Both North and South Dakota have strong wind resources and North Dakota also has low-BTU lignite
coal resources that it wants to continue to use. New high-voltage transmission lines are needed to
support the Dakotas’ ability to export electricity to neighboring states.

See also: ICF-Independent Assessment MISO Benefits

Anyway, here it is, and it’s much like Phyllis Reha’s puff piece promoting CapX 2020 years ago while she was on the Public Utilities Commission, that this is the model other states should use:

MN PUC Commissioner Reha’s Feb 15 2006 presentation promoting CapX 2020

So put on your waders and reading glasses and have at it. Here’s the word on the 2005 Transmission Omnibus Bill from Hell – Chapter 97 – Revisor of Statutes that gave Xcel and Co. just what they wanted, transmission as a revenue stream:

And note how opposition is addressed, countered by an organization that received how much to promote transmission.  This is SO condescending:

… and opposition discounted because it’s so technical, what with load flow studies, energy consumption trends, how could we possibly understand.  We couldn’t possibly understand… nevermind that the decreased demand we warned of, and which demonstrated lack of need, was the reality that we were entering in 2008.

And remember Steve Rakow’s chart of demand, entered at the very end of the Certificate of Need hearing when demand was at issue???  In addition to NO identification of axis values, the trend he promoted, and which was adopted by the ALJ and Commission, has NOT happened, and instead Xcel is adjusting to the “new normal” and whining that the grid is only 55% utilized in its e21 and rate case filings.  Here’s Steve Rakow’s chart:

Reality peak demand trajectory was lower than Rakow’s “slow growth” line, in fact, it’s the opposite from 2007 to present.  Suffice it to say:

Remember Xcel’s CapX 2020 peak demand projections of 2.49% annual increase?  How wrong can they be?  And how unjustified was their basis for a Certificate of Need for CapX 2020?  And how are they held accountable for those gross misrepresentations?  But now it’s time to pay, and who will pay?  This is why the rate case in progress, PUC Docket 15-826, is so important.

On the other hand, I love it when this happens… Xcel Peak Demand is again DOWN!  There’s a trend, and it’s called decreased demand.  Demand has yet to exceed the 2007 peak, and now it’s 8 years…

Here’s the Xcel Energy SEC 10-K filed a couple days ago:

2015 – Xcel Energy 10-K

Is it any wonder they want to get away from a cost based rate a la their “e21 Initiative” scheme?  Particularly now that the bill for CapX 2020 is coming due and their newest rate case (PUC Docket GR-15-826) is now underway?

And the specifics, and note how they inexplicably forecast a 2016 peak of 9,327, which is based on a “normal weather conditions” assumption:

When the Applicants added the Myrick route, oh-so-improperly at the very end of a long proceeding when they saw they couldn’t get their way due to DOT easements, it was excruciating.  Successfully defeated, but excruciating because it was so wrong, so ham handed, and yet accepted by the judge and the Public Utilities Commission.

So then they proposed a similar route for a smaller transmission line, the Tyrone line, years later.  What?  Whatever were they thinking?  Apparently they weren’t, and it doesn’t seem they knew about “Myrick” and anything that had come before.

GREAT recap of the first Planning Commission meeting here:

Substation, transmission lines will damage environment, opponents tell Planning Commission – Le Sueur MN_ News

Well, this is a subject I know all too well, and I’ve been brought into this Tyrone 69 kV transmission and substation proceeding at Le Sueur County.  Way too familiar.  The thing about this that’s NOT been made clear is that the utilities snuck in a big honkin’ substation and attached it to the Wilmarth line.  There was a plan to connect the CapX 2020 Helena sub to Wilmarth, and to link that to the St. Thomas substation, but though they did build the Helena sub connecting CapX with Wilmarth, there was no line to St. Thomas to the south.  Instead, and how they did this is beyond me, they built a brand new unplanned-for substation, called the Shea’s Lake substation, and connected that to St. Thomas.  Had to have cost at least $15 million.  ???  Where did that come from?

So back to this Tyrone project at Le Sueur County.  Emily Pollack had intervened in the proceeding, allowed under the Minnesota Environmental Rights Act, and now I’m representing her in this, and we just sent out some information requests and will see what we can see:

Cover_Le Sueur P&Z

Attachment Binder_FINAL

Cover_Applicants GRE & MVEC

There’s good stuff in the Attachment Binder, particularly the North Mankato Load Serving Study and the Biennial Transmission Plans showing their plans for local load serving.  Without the basic information on this project, there’s no basis for a decision by the County.

But here’s the rub — they built this new Shea’s Lake substation to serve the Le Sueur and Le Center areas, so folks, that’s the substation that should be used!  No excuse to build it for this purpose, and then not use it!

This Research Assistant job popped up — wonder who’s paying for this… and what’s the point?

I’ve been saying this for so many years, that electric demand is down, down, down, and instead, Xcel Energy (and all the others) have been saying it’s going UP, UP, UP (even though Mikey Bull said years ago that they wouldn’t need power for a while), and they’re applying for and getting Certificates of Need for all these permits for utility infrastructure that are obviously designed to market and sell the surplus, and the Public Utilities pretends to be oblivious (I say “pretends” because I cannot believe they’re that unaware and uninformed.).

This is a must read:

Xcel Compliance Filing_CN-13-606_20149-103251-02

Here’s the short version from Xcel:

2024 is expected to be about what it was back in 2007, the industry peak year.  DOH!  But note this — there’s a “small capacity surplus in 2016.”  DOH!

And given the surplus which we’ve known has been present and looming larger, that’s why they then ask for withdrawal of the Certificate of Need for the Prairie Island uprate because it isn’t needed (and really, that was just what, 80 MW or so?  Or 80 MW x 2 reactors, 160 MW?).  If they don’t need that small uprate, why on earth would they need so much more?

But what do I know…

Hollydale Transmission Line was clearly not needed, and they withdrew that application…

CapX 2020 transmission was based on a 2.49% annual increase in demand, and for Hampton-La Crosse in part supposedly based on Rochester and La Crosse demand numbers, yeah right, we know better, but that was their party line.  Again, DOH, it didn’t add up to needing a big honkin’ 345 kV transmission line stretching from the coal plants in the Dakotas to Madison and further east, but who cares, let’s just build it…

ITC MN/IA 345 kV line — the state said the 161 kV should be sufficient to address transmission deficiencies in the area, but noooooo, DOH, that wouldn’t address the “need” for bulk power transfer (the real desire for the line).

Here’s a bigger picture of the bottom line (I’m accepting this as a more accurate depiction, not necessarily the TRUTH, but close enough for electricity), keeping in mind that these are PROJECTIONS, and that they’re adding a “Coincident Peak adjustment” which should be included in the “peak” calculations):

Notice the only slight reduction in coal capacity, just 19 MW, nuclear stays the same, a 320 MW decrease in gas, a 128 MW reduction in Wind, Hydro, Biomass, which I hope includes garbage burners and the Benson turkey shit plant , slight increase in solar of 18 MW, and Load Management also a slight increase of only 80 MW.  This is Xcel Energy with its business as usual plan, which has to go.  We can do it different, and now is the time.

Will someone explain why we paid so much to uprate Monticello, and paid to rebuild Sherco 3?

From the archives:

500+ give LS Power a piece of their mind

DOH!  This is NOT rocket science.  This came out last month, posted on the CapX 2020 site, and around the same time, there was a PR push about the tax payments, “benefits,” that local governments were receiving for the CapX 2020 transmission lines.  This report is all about the “benefits” and not about the costs, let’s be clear on that:

WIRES Brattle Report – Benefits of Transmission Jul 2013

Now I’ll take a look at this…

What it looks like is advance work for the 765kV overlay, for which there is no logical “need” claim.  They want to turn “planning” on its head, and put “benefits” at the top, the first item on the check list, in “planning.”  I’ll be using a lot of “quotes” here because I’m not buying it.

What they advise, what they’re trying to sell, is that transmission planning should:

1) Identify potential transmission projects that could supplement or replace baseline reliability projects and to develop a comprehensive list of their likely benefits.

2) Estimate the value of as many of the identified benefits as practical.

3) Determine whether the proposed transmission investments would be beneficial overall by comparing the magnitude of estimated economy-wide benefits with estimates of the total costs of the projects.

4) Address cost allocation.

They say that “planners must plan for the highest value first…”

Citing my favorite Posner decision, they quote, “To the extent that a utility benefits from the costs of new facilities, it may be said to have “caused” a part of those costs to be incurred, as without the expectation of its contributions the facilities might not have been built, or might have been delayed.

Illinois Commerce Commission v FERC (7th Cir.)

Benefits should be weighed at the outset when assessing need, in essence benefits supplanting need as reason for a transmission project.  Yeah, OK, what’s new???

(still reading)

Transmission — it’s all connected.  In looking at the Minnesota rulemaking, and the existing and proposed rules that utilize the word “regional,” I’m thinking about big picture stuff, the big proposals in the wings, and that Joint Coordinated System Plan (JCSP) map sure presents a big picture. For some reason, I’ve not been able to find the full JCSP report until recently:

JCSP_Report_Volume_1

JCSP_Report_Volume_2

Who cares about JCSP?  Well, WE’D better care, because look who’s paying for the transmission build-out (p. 68 of Vol. 1):

Look at the numbers for Midwest ISO, a $-10,293, or for MAPP, a $12,292, that’s a COST, not a savings.  MISO and MAPP get nominal production cost savings and massive load COSTS.  This is not news, but is worth repeating as we discuss “regional.”  And another take with the same take-away of big costs for MISO and MAPP customers, used by our good friends at  AWEA to promote this transmission buildout in their flyer called “Green Power Transmission and Consumer Savings” (flyer below):

Read the whole thing:

AWEA_Transmission_and_Consumer_Savings

What a deal, eh?

Look what AWEA has been advocating to make this happen:

Federal Siting

In addition to regional planning and cost allocation,

substantial reform of the transmission siting process is

required to meet national renewable energy goals. The

most effective model is the siting authority that was given

to FERC over interstate natural gas pipelines. For green

power superhighways, the extra-high-voltage facilities

defined in the regional plans would be subject to FERC

approval and permitting. Separate siting approval at the

state level would not be required. FERC would act as the

lead agency for purposes of coordinating all applicable

federal authorizations and environmental reviews with other

affected agencies.

AWEA – Green Power Superhighways